US NRC Regulatory Guide 1.33 QA Program (operation) Rev 2 1978 Page 11 of 11Revision 2February 1978Regulatory Guide 1.33Quality Assurance Program Requirements (Operation)A. IntroductionAppendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Licensing of Production and Utilization Facilities, establishes quality assurance requirements for the operation of nuclear lower plant safety-related structures, Systems, and components. This regulatory guide describes a method acceptable to the NRC staff for complying with the Commissions regulations with regard to overall quality assurance program requirements for the operation phase of nuclear power plants. The Advisory Committee on Reactor Safeguards has been consulted concerning this guide and has concurred in the regulatory position.B. DiscussionSubcommittee ANS-3, Reactor Operations, of the American Nuclear Society Standards Committee developed ANSI N18.7-l972, which contained criteria for administrative controls for nuclear power plants during operation. This standard, along with ANSI N45.2. 1971, Quality Assurance Program Requirements for Nuclear Power Plants, was endorsed by Regulatory Guide 1.33. The dual endorsement was necessary in order for the guidance contained in the regulatory guide to be consistent with the requirements of Appendix B to 10 CFR Part 50; however, this dual endorsement caused some confusion among users. To clarify this situation, ANSI NI 8.7-1972 was revised so that a single standard would define the general quality assurance program requirements for the operation phase This revised standard was approved by the American National Standards Committee N IS, Nuclear Design Criteria It was subsequently approved and designated N18.7-1976/ANS-3.2, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants,(1) by the American National Standards Institute on February 19, 1976.There had been some uncertainty with regard to the NRC staffs position when a regulatory guide endorses, as an acceptable method, the guidelines as well as the requirements included in a standard. The NRC staff has evaluated the guidelines contained in N18.7-1976/ANS-3.2 with respect to importance to safety. Revision I of this regulatory guide clarified the NRC staffs position on the requirements and guidelines included in ANSI N 18.7- 1976/ANS- 3.2. Where conformance to the recommendations of this regulatory guide is indicated in an application without further qualification. this indicates the applicant will comply with the requirements of ANSI N18.7- 1976/AN5-3.2, as supplemented or modified by the regulatory position of this guide.Section I, Scope, of ANSI N18.7-1976/ANS-3.2 states that this standard contains criteria for administrative controls and quality assurance for nuclear power plants during the operational phase of plant life and that (his phase is generally considered to commence with initial fuel loading, except forcer-lain preoperational activities. In this regard, a separate regulatory guide addressing the quality assurance program for the preoperational phase will be issued. Other regulatory guides may be issued or this regulatory guide may be revised, if necessary, to amplify the general requirements contained in this standard.Appendix A to this guide has been further revised as a result of additional comments received on the guide and additional staff review.C. Regulatory PositionThe overall quality assurance program requirements (or the operation phase that are included in ANSI NIS .7-I 976/ANS-3.2 are acceptable to the NRC staff and provide an adequate basis (or complying with the quality assurance program requirements or Appendix B to 10 CFR Part 50, subject to the following:1.ANSI N18.7-l976/ANS-3.2 requires the preparation of many procedures to carry out an effective quality assurance program. Appendix A. Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors, to this regulatory guide should be used as guidance to ensure minimum procedural coverage for plant operating activities, including related maintenance activities. Appendix A lists typical safety-related activities that should be covered by written procedures but does not provide a complete listing of needed procedures. Many other activities carried out during the operation phase of a nuclear power plant require written procedures not included in Appendix A. Appendix A may also contain procedures that are not applicable to an applicant because or the configuration of the nuclear power plant. The procedures listed in Appendix A may be combined, separated, or deleted to conform to the applicants procedures plan.2.Throughout ANSI N1S.7-1976/ANS-3.2, other documents required to be included as a part of this standard are identified at the point 0f reference. The specific acceptability of